Matthew R. Galeotti’s Insights on Combating Financial Crimes: A Call to Action
Thank you, Bernard, for that warm introduction, and a heartfelt appreciation to SIFMA for inviting me to speak at this year’s Anti-Money Laundering and Financial Crimes Conference.
Our Collective Mission: Protecting Hard-Working Americans
Over recent months, the Department of Justice has underscored its unwavering commitment to safeguarding hard-working Americans from the most significant threats. The Criminal Division is diligently working to dismantle criminal networks including cartels and transnational criminal organizations (TCOs), combat human trafficking, disrupt the flow of dangerous substances like fentanyl, and hold accountable those preying on the vulnerable in our communities.
The Critical Threat of White-Collar Crime
It’s important to note that white-collar crime represents a significant danger to U.S. interests. Unchecked fraud within our markets and government programs not only robs hard-working Americans but undermines our broader economy. The activities of cartels and TCOs are frequently facilitated by international money laundering organizations, which pose risks to our national security by enabling sanctions evasion by hostile regimes.
The Role of the Criminal Division
Today, I want to share the pivotal role our Criminal Division plays in tackling these formidable challenges. As a leader in white-collar enforcement, we are dedicated to preventing market distortions stemming from fraud and deception. However, it’s become evident that our approach must evolve.
The Need for Clarity and Cooperation
Businesses today yearn for clear guidance and certainty in their dealings with us. Too often, companies find themselves ensnared in lengthy investigations that not only drain resources but also interfere with day-to-day operations. This uncertainty has, regrettably, deterred many from cooperating with the Department, diverting our focus away from the most pressing threats.
Beneath this complex landscape lies a fundamental truth: if companies believe the Department will be punitive without clear incentives, we risk generating prolonged investigations detrimental to all parties involved.
A New Era in White-Collar Enforcement
Recognizing that law-abiding companies are essential to a prosperous America, we are embarking on a new strategy in white-collar and corporate enforcement. The time has come to foster a symbiotic relationship where businesses can thrive without the fear of retribution.
Reinforcing Compliance Professionals
Today, I want to emphasize a crucial truth: many corporations and financial institutions aim to play by the rules. Compliance professionals like those of you present here are the first line of defense against criminal actors. Your daily efforts to establish robust compliance programs are vital in protecting your companies, shareholders, and customers.
Unveiling the White-Collar Enforcement Plan
I’m excited to announce our new white-collar enforcement plan, which aims to concentrate on the most egregious offenses while streamlining our approach to corporate enforcement. This plan prioritizes:
- Victim Rights: Ensuring that the rights of victims are honored.
- Resource Maximization: Using our limited resources to focus on the most severe threats.
- Transparency: Offering fairness and clarity to both individuals and companies.
Key Changes in Corporate Policies
Under this new administration, we’re simplifying existing policies, including the Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). This revamped policy aims to clarify outcomes for companies that choose to come forward.
The primary takeaway? Self-disclosure is now the key to accessing the most generous benefits the Criminal Division can offer. Companies that meet specific criteria will not only receive consideration but may also avoid burdensome penalties.
Enhanced Monitoring Policies
Furthermore, our monitor selection policy is undergoing revision. We recognize that excessive monitoring can become a financial burden on compliant businesses. Our approach aims to ensure that any imposed monitor’s costs are justified by the value they provide—striking a balance between oversight and operational efficiency.
Fostering a Culture of Reporting
Lastly, we’ve enhanced our corporate whistleblower program to better reflect our commitment to tackling the most serious crimes. We are expanding priority areas to include:
- Procurement fraud
- Trade and customs violations
- Sanctions and material support for terrorism
By doing so, we’re sending a clear message: we want to incentivize reporting that yields actionable intelligence against the most egregious offenses.
A Togetherness For the Greater Good
In conclusion, I urge all compliance professionals—especially those in anti-money laundering and financial crime sectors—to take this message back to your companies: now is the opportune moment to report, remediate, and strengthen compliance to ensure a prosperous future for America.
The benefits of self-reporting have never been clearer. As the eyes and ears of your organizations, you have the unique opportunity to fortify our collective efforts against fraud, ensuring that rogue actors are brought to justice without penalizing those who strive to do right.
Thank you once again for your time and commitment to this vital work.
For more insights and updates on our initiatives, check out our resources:
